Privacy Policy

EFFECTIVE: October 15, 2018

COMMITMENT TO PRIVACY

At Crowley Webb and Associates, Inc. (“The Company,” “We,” “Us”), We are committed to protecting your privacy. This Policy explains our data collection practices and your choice about the way your information is used on our Websites (www.crowleywebb.com and www.gopraxis.com) and our Platform (www.praxisdirect.com). In order to find this Privacy Policy, We have committed to making it available on every page of the corporate website and all study websites, PraxisDirect®, and all mobile device applications. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged The Company.The Company (Crowley Webb and Associates, Inc. and its wholly owned subsidiary Praxis Communications, LLC) participates in and has certified its compliance with the EU-US Privacy Shield Framework. The Company is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the US Department of Commerce’s Privacy Shield List (https://www.privacyshield.gov/list)..

The Company is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. The Company complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.With respect to personal data received or transferred pursuant to the Privacy Shield Framework, The Company is subject to the regulatory enforcement powers of the US Federal Trade Commission. In certain situations, The Company may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.If you have an unresolved privacy or data use concern that We have not addressed satisfactorily, please contact our US-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, which are more fully described on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

APEC Participation

Crowley Webb and Associates, Inc. privacy practices, described in this Privacy Policy, comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. More information about the APEC framework can be found here.

GDPR Participation

The Company (Crowley Webb and Associates, Inc. and its wholly owned subsidiary Praxis Communications, LLC) participates in and has self-certified its compliance with the EU General Data Protection Regulation (GDPR). To learn more about GDPR, visit the European Commission website (https://eur-lex.europa.eu/eli/reg/2016/679/oj).

PERSONALLY IDENTIFIABLE INFORMATIONWe implement security measures to protect any personally identifiable information that We transmit or store. We collect your name, email address, and phone number. When you employ the email contact feature, We do not collect any personal information about you unless you provide Us that information voluntarily. Any information you provide Us in an email contact is used only to respond to your inquiry, which may be by email or a phone call from one of our representatives if you provide phone contact information. Any information you voluntarily provide to Us in a questionnaire on a study website is used only to enable the local research site in your area to contact you about that study, and only with your consent. Any information your local research site provides Us about you is used only for setup and functionality of clinical research study mobile device applications once you have enrolled into a clinical research study.

When you download and use our Services, we automatically collect information on the type of device you use, and operating system version.SENSITIVE INFORMATIONIf We collect information from you specifying medical or health conditions; racial or ethnic origin; political opinions; religious, ideological, or philosophical beliefs; trade union membership; information on social security measures or administrative or criminal proceedings or sanctions (which are treated outside pending proceedings); or information with respect to personal sexuality (collectively, “Sensitive Information”), We will not (a) disclose such Sensitive Information to a third party or (b) use such Sensitive Information for a purpose other than those for which it was originally collected or subsequently authorized by you without obtaining your affirmative “opt-in” (unless We believe in good faith that We are required to do so in order to comply with an applicable statute, a regulation, a rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process).HIPAA COMPLIANCEAlthough The Company is not a covered entity according to the Health Insurance Portability and Accountability Act (HIPAA), and the information gathered on our study prescreening questionnaires is the equivalent of a survey rather than a medical record, We understand that information supplied on such online forms may be of a sensitive nature and that the research sites We work with must comply with HIPAA guidelines. Therefore, the confidentiality of the personally identifiable information is vigilantly maintained and secured.HOW WE USE PERSONALLY IDENTIFIABLE INFORMATIONThe Company does not disclose, give, or sell any personally identifiable information you provide in an email inquiry form or in response to clinical research study recruitment campaigns to any outside organizations for any reason (other than where We may be required to by law and as stated in this Policy). This includes information voluntarily provided by users via The Company recruitment websites and any patient information entered by research sites from their own recruitment efforts. Research sites utilizing PraxisDirect for clinical recruitment trials agree to keep their login information private and handle accessible data in compliance with this Privacy Policy and any confidentiality and/or privacy agreements executed between the research site and the clinical trial sponsor in relation to the study data. At the close of each recruitment campaign, all personally identifying information housed in PraxisDirect is deleted, retaining only aggregate data for analyses. We may also disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when We believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You may sign up to receive newsletters from Us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails We send to you, or please click here to send Us an email.OUTSIDE CONTRACTORSWe may employ independent contractors, consultants, vendors, and suppliers, such as a call center, a mail house, or any other third party who may need to receive or handle personally identifiable information on our behalf (collectively, “Outside Contractors”) in connection with the performance of obligations and exercise of rights under this Privacy Policy and the Website Terms and Conditions and to provide specific services and products related to the Website, such as hosting and maintaining the Website, providing fraud screening, providing shipping services, and developing applications for the Website and email services. In the course of providing products or services to Us, these Outside Contractors may sometimes have access to information collected through the Website, including your personally identifiable information. We require these Outside Contractors to agree in writing: to provide at least the same level of privacy protection with respect to your personal information as is required by this Privacy Policy; and not to use your personally identifiable information for any purpose other than the purpose for which We retained them.DATA SECURITYThe Company will take reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. The Company cannot guarantee the security of Information on or transmitted via the internet.DATA INTEGRITYThe Company will process Personal Information only in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, We will take reasonable steps to ensure that Personal Information is accurate, complete, current, and reliable for its intended use.ACCESS, CORRECT, OR DELETE YOUR INFORMATIONUpon request, The Company will provide you with information about whether We hold, or process on behalf of a third party, any of your personal information. To request this information please click here to send Us an email.Contact Us to update or remove the information you provided to Us. In order to protect your privacy, We will take reasonable action to verify your identity before changing or updating your information. Please refer to the section “How to Contact Us” below. We will respond to your request within a reasonable time frame.LINKS TO OTHER WEBSITESOn occasion We may make available on our website links that will give you access to other websites that may be of interest to you but that We do not control. We cannot be responsible for the privacy policies of such other websites. If you submit personal information to any of those websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.TRACKING TECHNOLOGIESWe and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level. As is true of most websites, We gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.We do not link this automatically collected data to other information We collect about you. We partner with a third party to either display advertising on our website or manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based on your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt out by clicking here (or, if located in the European Union, click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads. DISCLOSURES SPECIFIC TO THE PLATFORMThe Company collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that uses our service, please directly contact the Client with which you interact. We may transfer personal information to companies that help Us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.The Company has no direct relationship with the individuals whose personal data it processes. An individual who seeks to access data, or who seeks to correct, amend, or delete inaccurate data, should direct his/her query to The Company’s Client (the data controller). If requested to remove data, We will respond within a reasonable time frame.We will retain personal data We process on behalf of our Clients for as long as needed to provide services to our Client. The Company will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.PRIVACY POLICY CHANGESIf the way We treat personally identifiable information changes in any material way, such changes will be included in an updated version of this Policy prior to the change becoming effective and will be posted in this same location. We will use personally identifiable information only in accordance with the terms of the Policy under which it was collected. Please check back to ensure you are familiar with the most recent Privacy Policy.HOW TO CONTACT USIf you have any questions, concerns, or complaints about our privacy policy or how We handle your personally identifiable information, please contact our privacy officer at Crowley Webb and Associates, Inc., 268 Main Street, Suite 400, Buffalo, NY 14202, or click here to email. Our privacy officer will immediately investigate any complaint about our use of your personally identifiable information. ACCEPTANCE OF PRIVACY POLICYBy using our corporate website, any study websites, PraxisDirect, or any mobile device applications, you signify your assent to our Policy. If you do not agree with this Policy, you are not permitted to use our websites or mobile device applications.

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